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You must keep documentation that the seed planted during your transition meets these requirements as part of your application for organic certification. If you plant a corn seed treated with captan after two years of transitioning to organic, for instance, you must restart the 36-month clock on your transition, to the day you planted that seed on that field. If you are unsure if a seed treatment is allowed, ask MOSES, or the organic certification agency you are planning to use when you become certified for organic production.
If your operation is certified organic, you are required under the organic regulations to plant organic seed, unless you cannot find an “equivalent organically produced variety” in the form, quality or quantity that you want. For example, you may want organically approved clay-coated carrot seed for ease of planting, and it is not available on organic seed; or, you want 1000 pounds of bodacious sweet corn seed and you cannot find organic seed in that quantity; or, the germination rate for the organic barley you found is only 65%; or, you cannot find the specific variety of seed in an organic form that the buyer of your crop wants you to grow. In all of these cases, you can use non-organic seed. It cannot have prohibited seed treatments, as described above.
Note that the rule requires you to seek out an “equivalent” variety. If you are new to organic and are unsure whether the organic seed varieties are equivalent to the familiar non-organic varieties you are used to growing, you should trial out organic varieties with similar characteristics at the same time as planting your untreated non-organic seed, to see if you can find one to your liking. Higher price is NOT an acceptable reason to avoid planting organic seed.
Organic seed is an investment in our future as organic producers. Since organic seed is produced under organic management, and the seed breeders are specifically working to provide characteristics that organic crop producers need, it makes sense to purchase from these companies and support their efforts. For example, organic corn producers cannot plant in cold ground in the early spring, since their seed is not treated with fungicides. Therefore, they want a seed that will germinate quickly as well as canopy thick and early to help with weed control in their organic fields. Organic seed breeders work to have crops that respond well to natural, slower release forms of fertility inputs, whereas nonorganic corn seed breeders don’t do this.
I have the opportunity to rent some pasture from my neighbor who hasn't used it in many years. What do I need to do to get this certified, and what is the best way to start pasturing organically?
Make sure that prohibited substances have not been used for at least three years. It is not uncommon to find that the owner may have spot treated weeds or applied manure. If herbicides have been used, it will take a full three-year transition from the last application date before the land can be certified. Conventional manure is allowed, but be sure that the manure and bedding source does not contain prohibited materials like recycled lumber waste, has not been treated with herbicides or insecticides or had chemical treatments to control odor or nutrient loss. Ask a lot of questions to be sure there are no surprises.
A soil test should be a top priority. Fallow land may or may not be fertile. The soil type and previous land use have a large impact on the quality of the soil. Large fields may even have multiple soil types and can vary in fertility from location to location. It is extremely rare to find a soil that isn’t lacking in some nutrients, and may even have an overabundance of others. The soil test can help you plan for the right fertilizer applications.
In general, fallow land tends to need renovation: fertility amendments and, often, reseeding for improved forage quality. Fallow land tends to revert to lower quality grasses over time. So you should also take an assessment of the plant population and type. You can request an assessment and assistance with a grazing plan from the Natural Resources Conservation Service, (NRCS) which will have a grazing specialist available for consultations. If you look in the blue pages (government pages) of your phone book, you can find your county NRCS office. The grazing specialist can help you assess your pasture quality, help you design a fencing and paddock layout and can determine ideal stocking rates. The NRCS also has programs providing cost share for some of these improvements, if you have a long-term lease on this pastureland.
Pastures, too, can revert to low-quality grasses and plants will need to be renovated. Ideally you want a mixture of cool and warm season grasses and a mix of legumes and other broadleaf plants to provide a resilient mix of forages throughout the growing season and changing climatic conditions. Legumes can sometimes be seeded into existing pastures by broadcasting them at the right time of year, typically late winter. If the thatch (root mass and decaying materials) is very thick, you may need to use a no-till seed drill to open up the soil enough for the new seed to make contact. These drills can sometimes be rented through local grazing groups. Good fertility, the right plant population and a good rotational paddock design are the keys to getting good production on your new pasture. Make sure you follow all requirements for your seed, such as planting organic seed or using seed that does not contain any prohibited treatments or inoculants.
Fencing that is already in place can be used even if the posts had been treated with prohibited materials, although your certifier may require an interior fence to prevent grazing right next to these posts. Any new fencing must comply with organic standards and cannot contain these prohibited materials.
205.206 (f) The producer must not use lumber treated with arsenate or other prohibited materials for new installations or replacement purposes in contact with soil or livestock.
Natural wood, metal posts, and concrete posts are allowed. AC2 copper-treated posts are allowed with restrictions such as having a buffer in place between the posts and organic grazing land.
Check with your certifier for details about fencing.
Buffer zones are required along any pasture that borders conventional fields. A 25-30 foot buffer, which cannot be grazed or harvested for organic use, will help prevent contamination from neighboring conventional fields. In most cases, an interior electric or similar fence will be adequate. The buffer zone can be harvested mechanically, or by grazing non-organic livestock such as horses, it cannot be sold or used as organic.
Dairy farmers who want to ship organic milk and apply for first time organic certification during the winter months may need to have two inspections in one year. The first would be to review livestock activities and growing systems during the winter, and the second to actually view crops and pasture during the growing season in the summer.
Meat producers might need to purchase organic forages and grains this coming winter or spring in order to produce or sell organic animals next year. Brood animals must consume certified organic feed while they are in the last third of gestation in order for the offspring to be sold as organic meat animals. There cannot be retroactive organic certification for a previous year’s hay or grains, since they were not physically inspected while they were growing.
The ability to get certified this year also depends upon the certification agency’s workload and the inspector schedule. Most certification agencies can handle a limited number of “rush” applications. However, if the timeline is too short, or if the agency is already at capacity, it may be too late. In general, even a rush application will take a month to process from the time you submit your application to the date you receive your organic certificate. The initial review, the inspection and the final review are all required, and while they can be prioritized, they still take time and effort to be done correctly. A simple operation with only a few crops stands a better chance of getting a late season rush done than does a complicated farm with several crops, livestock and crops, or farms with processing facilities.
Ultimately, only the certification agency can tell you if you can obtain a late season organic certificate. Call your potential certification agencies immediately, explain your situation, and find out what your options might be.
If you sell bulk products with no retail label, you probably don’t need to go through the expense and time of registering a trademark–this is especially true if your farm name includes your family name, such as Smith Family Dairy or Johnson Farms.
The first step in getting a trademark for your farm name is to register the name with your home state and surrounding states if you plan to do business there. For many farms, this step provides enough protection and a national trademark is not necessary—you’ll need to assess your own risk to determine if state registries are sufficient.
To find a state registry, search the Internet for “trademark registry [state name].” These registry websites have a search feature that lets you enter the name you want to trademark to see if someone else has already registered that name in that state. If the name is available, you can follow the instructions on the website to register your farm name. The cost to do this can range from $15 to $100, depending on the state. Registering your farm name this way gives you legal protection to challenge others who try to use the same name. It does not guarantee that someone would not use your name outside of the registry system.
To obtain broader legal protection for your farm name, you would need to trademark it on the national level. Start by searching for your farm name in the Trademark Electronic Search System (TESS) at www.uspto.gov/trademarks. In fact, it’s worth your time to conduct a search even if you’re only going to enter your name in state registries. You could run into trouble, as I have, if you use a trademarked name even locally.
I have used my farm’s name for more than 20 years without a trademark or state registry. I recently received a “cease and desist” order from a company in California who had federally trademarked “Sweet Earth” 25 years ago in numerous food categories, including fresh produce. I am now in the midst of changing my farm’s name, a difficult and time-consuming process, but better than a lawsuit that I would lose if I tried to keep my farm’s name.
Obtaining your own national trademark involves a lot of searching, documentation and time. You can go through numerous confusing steps on the national trademark website and do it yourself, but I recommend hiring a lawyer that specializes in trademarks. The cost to hire a trademark lawyer to set up a national trademark will be $1,000 or more.
Once your name is trademarked, you must maintain that trademark by periodically informing the state or federal agency that it is still in use. This might be every three, five or ten years depending on the agency. Typically, there is not a fee for renewal of trademarks, but that might change.
Take time to think about potential future endeavors involving your farm name. If you decide you’ll market products under your farm name, do a thorough trademark search and register that name. Consider getting a trademark for your logo at the same time—it can save you time and money to do both trademark searches and applications together.
At farmers’ markets, where these exempt-from-certification growers often sell products, labeling can become an issue. It is unfair to producers who go through the strict requirements to achieve organic certification to see the label misused. In many cases, misuse is a result of ignorance, not malice. But, it can cause bad feelings between growers at a market, and impact a market’s reputation if patrons see “organic” being used loosely.
To ensure that vendors at a farmers’ market are using “organic” correctly, managers can ask them to sign a statement that they have followed organic rules. This not only makes vendors aware of the standards they must meet, but also satisfies certified organic farmers that their market neighbors are meeting the same strict rules.
The statement below covers many of the requirements that a smaller scale grower or livestock producer must meet in order to sell organically labeled products as a noncertified (“exempt”) organic farmer. It provides information on what practices and inputs are allowed in order to use the organic label, and can be a valuable educational tool.
Farmers’ market managers should feel free to modify this statement and have it reviewed by their own legal counsel. This type of statement should be updated each year to keep current with changes to organic regulations.
NOTE: Anyone may file an anonymous complaint at NOPcompliance@usda.gov to report someone who is making an organic claim who is not certified or exempt from certification requirements.
Statement for exempt-from-organic-certification producers to use the word “organic”
I am a producer that is not certified organic, but I use the word “organic” to describe my products or practices in the marketplace. The list below describes many of the requirements in the organic law that I follow in order to use the word “organic.” I have read and follow the full U.S. organic regulation, which is located at www.ams.usda.gov/nop.
I affirm that:
1. I sell less than $5,000 annually in organically labeled products.
2. I have not planted any seeds that had synthetic treatments, such as fungicides or insecticides.
3. I have planted all organic seeds if they were available in the variety and quantity I required.
4. I have either grown transplants myself using only OMRI* or organic certifier organically approved potting mixes and other inputs or I have purchased certified organic transplants.
5. I have only applied fertility, pest, disease and weed management inputs that have either been approved by OMRI or by an organic certification agency. I understand that there are numerous agricultural input products that make organic claims that are untrue and I have gone the extra step to verify what I am using meets the organic law.
6. I have implemented a soil building rotation on my farm, where annual crops of the same type are not grown in succession in the same field. I also use plant and livestock based materials such as cover crops and compost to continually improve my soils.
7. I have not applied manure to my fields growing crops for human consumption any sooner than 90 days before harvest for crops that are not in contact with soil (i.e. sweet corn), or 120 days before harvest for crops that are in contact with soil (root crops, tomatoes, peppers etc.).
8. I have documentation that compost containing livestock originated components used on my farm meets the requirement of having a Carbon to Nitrogen ratio of between 25 to 1 and 40 to 1, has had a temperature maintained of 131 to 170 degrees F for 15 days and has been turned 5 times, or if in a static vessel, had this temperature maintained for 3 days.
9. All mammalian livestock has been managed organically from the last third of gestation of their mother to the day of slaughter. All poultry has been managed organically from the second day of life. Organic management includes 100% certified organic feed.
10. All livestock has had access to the outdoors, with ruminants receiving 30% of their nutrition from pasture during a minimum 120 day grazing season. All animal health products and feed supplements have either been OMRI approved or approved by an organic certification agency.
11. I have maintained documentation that verifies what I have stated above.
*OMRI=Organic Materials Review Institute (www.omri.org)
I think that I am renting out my cropland for too little money. What is the going rental rate for organic cropland?
People often think that because land is certifiable as organic, and because the organic premium is higher than conventional prices, that organic cropland can command higher rental rates. This is definitely not true. Organic farmers are usually not willing to pay any more than the going rate for similar conventional cropland —nor should they, for a number of reasons.
Conventional farmers can focus only on the two most profitable crops: corn and soybeans. The advent of GMO, glyphosate-tolerant crops has allowed the two-crop rotation to become the norm. Spray for weeds, spray for pests, add synthetic fertilizer as needed and, as long as you have insurance to cover disaster and subsidies to cover low pricing, you have a “can’t-fail” system that is driving rental and land prices to historic highs.
Organic farmers cannot, by law, continually plant row crops year after year. They must use farming practices that protect and build soil. So they have more complex crop rotations that include cover crops, small grains and forages. They also cannot use the time- and labor-saving herbicides and pesticides. So they must have a much more long-term approach to build soil and control pests. It is not uncommon to see five- to seven-year rotations in organic row crop systems. Organic small grains and forages do not command the same premiums as corn and soybeans. Knowing that, organic farmers are unwilling to pay more than the going rate for rental land, and they usually want longer rental contracts to reap the results of soil building.
Organic farmers, also by law, have to protect the natural resources of the land they farm. The fence row to fence row, put-everything-under-cultivation approach of conventional row crop farmers may make perverse sense economically, but it has been a disaster for our natural re-sources. An estimated eight million new acres of previously unfarmed land, much of it sensitive wetland or previously conserved acreage, has gone under cultivation, mostly to conventional production, over the past five years due to the insatiable quest for more cropland.
Organic farmers must protect wetlands, streams and natural areas by rule, and because having diversity actually helps protect against disease and pest outbreaks. Landowners need to take into account long-term goals for their land, and not just consider the highest possible rental price when considering with whom to rent their land. If bulldozing down trees, ripping out fencerows, tearing out contour strips and terraces, filling in wetlands, spraying it all with glyphosate, and dousing it with anhydrous ammonia sounds incompatible with your land use vision, you should take that into account when negotiating rental rates with organic farmers.
Cropland rental rates vary considerably from region to region. Soil quality and land quantity are the main factors to consider. Marginal land that needs a lot of inputs to be productive will be on the low end, while larger acreages of high quality soil will command the highest rates. Rental rates may be as low as $125 and up to $250 or more per acre for the most desirable cropland. The best way to determine local rates is to talk with your county’s University Agricultural Extension Agent. They are usually familiar with the going rates in your area. Getting a soil test and understanding the results can help when negotiating rental rates.
It pays to talk with potential renters about their management practices. Ask them about their crop rotation plan, pest and weed control, their soil-building practices, and how they plan to prevent erosion and protect sensitive natural areas. Organic farmers should be able to explain their management practices. Landowners who care about the stewardship of their land should and will make their rental decision on more than maximizing rental rates.
For more information about organic contracts and rental agreements, see the the Farmers’ Legal Action Group (FLAG) website at www.flaginc.org/publication/farmers-guide-to-organic-contracts.
I am having my organic corn (or soybeans or small grains or hay) custom harvested. What should I do to protect the organic integrity of my crop?
When using a combine to harvest grains, soybeans or corn, the machine must be cleaned thoroughly between any non-organic crop and the organic crop. If the combine operator is working with another organic operator before harvesting your crop, you may not need to have the combine cleaned. You will need documentation that the last crop run through the combine was organic, and not a buffer strip, a transitional crop, or non-organic crop the other organic producer may have grown.
Cleaning a combine is labor-intensive and still may not remove all traces of a non-organic crop. Running the combine with all of the doors open is one way to shake out kernels and dust. Blowing out with compressed air and/or a shop vac is also an option. After either of these is done, you also must run the combine through a swath of your organic field, separating the first 30-60 feet or more of the crop that has been harvested. This harvest must be stored, used and/or sold as conventional. Keep a receipt or other documentation to show your organic inspector that this combine “purge” was either fed to your own non-organic livestock or sold as conventional. The distance you harvest for this combine “purge” depends on the size of the combine and the density of the crop. You should be able to justify to your inspector the amount of your purge. Typically it is 10-20 bushels.
Combine cleaning is done routinely by farmers who grow crops to sell as seed in order to maintain seed purity. Many custom operators know how many bushels they need to run through their combine to remove traces of the previous crop, especially if they combine small grains in mid-summer and then beans and corn. You must document who cleaned the combine, what they did and when. Some manufacturers may have information on how many bushels must be run through the combine to clean it out.
If the previous non-organic crop was Genetically Modified (GMO), even a trace of non-organic crop dust in your organic crop could result in a positive GMO test and rejection of your organic load if and when it is tested by the buyer. An ounce of prevention is definitely worth a pound of cure in this case.
If someone is custom harvesting your hay or swathing your small grains, make sure the equipment arrives at your organic field clean. The cutting and windrowing equipment is easy to inspect. If it is traveling any distance over the road it has most likely been shaken enough to remove any non-organic hay or straw. This is true for large round balers, as they are mostly self-cleaning. However, it is still your responsibility as the organic producer to verify and document that there is no residue of non-organic crop in or on the equipment before it is used to harvest your organic hay or straw. If a custom operator first harvests your own conventional hay, a buffer zone, or transitional hay, you will need to clean the equipment before using it on your organic crop.
Small- and large-square balers are more problematic since they typically retain a partial bale or two. You will need to run at least three small-square bales or one large bale of your own crop through the machine as a “purge,” and document that these were stored and sold or used as non-organic. Many large square balers have some sort of preservative that is injected into the large bale. The preservative container should be emptied of any prohibited substances before the baler is used to harvest your organic crop; note this in your records. If the product is a bacteria or other naturally occurring substance you should verify with your certification agency that it would be allowed on your organic bales. Ask your custom operator what type of preservatives might be used in the equipment, and check it with your certifier at least a week before the operator shows up to bale your hay.
Rented storage areas as well as any transportation vehicles also must be verified clean and free of previous crop residues or prohibited substances before being used for organic crops. Document that you verified they were clean before you used them. This documentation can be part of your field activity log or calendar, or you can use the various forms your certification agency may provide.
I shipped one load of organic corn, and it was rejected by my buyer as having GMO contamination and was then sold to a conventional buyer. What should I do for my next load?
Before signing a contract for purchase of your crop, or selling a crop on the spot market, it would be a good idea to find out what, if any, GMO testing is done and what level of GMO contamination would cause the load to be rejected by the buyer you are considering. You can also find out what level of GMO contamination your previous load had, and try to take some precautions next year when planting corn to lower your risk and level of contamination. You might try planting later than your neighbor to avoid cross pollination, increasing the size of your buffer strip, or choosing to grow corn where it is more isolated from neighboring GMO corn. Even though corn pollen will travel great distances, higher levels of contamination will occur when the non-GMO and GMO corns are grown in close proximity.
Typically, all organic crops sold for direct human consumption are tested for GMOs, sometimes numerous times in the process of cleaning and readying for sale. However, most livestock feeds are not tested for GMOs. In 2011, a report by the Office of Inspector General noted this lack of GMO testing of organic livestock feed, and encouraged the National Organic Program to require more testing of livestock feeds, especially those sold to organic dairy farmers. At this time, there is no specific direction from the NOP on GMO testing of organic livestock feeds.
It is unfortunate that the organic farmer bears the brunt of the weakness of GMO technology; that it is promiscuous and does not stay on the user’s side of the fence. Depending on the amount of GMO contamination, you may have the option of selling your crop as organic to another buyer with lower requirements, telling that buyer about the GMO contamination.
I have some organic corn and hay to sell, but see the prices have dropped from last year. Why the change?Answer by Organic Specialist Joe Pedretti:
Prices for both organic and non-organic corn and hay are lower than in recent years because the supply is greater now, and the demand is lower. Weather was one factor behind the unusually high grain and forage prices in 2012 and 2013. Drought during the summer of 2012 caused a lot of crop failures and substantially reduced yields everywhere. Forage production suffered, too, causing many livestock farmers to dip into their stored feed supplies much earlier than normal. The unusually long and cold spring of 2013 only increased the shortage problem.
Demand rose for purchased feed because of these shortages, but also due to increased demand for organic dairy products. Most of the organic milk companies were expanding their new farm base during this same time period to meet consumer demand. These two factors created strong demand for a very limited supply of feed and drove prices up to historic highs late in 2012 and through the first half of 2013.
2013 saw a reversal in fortunes for both supply and demand. Despite the slow, cold start, organic grain and forage production was good to excellent in most areas of the country. Pasture was ample, so farmers were able to restock their hay and silage stores. 2013 also saw a softening of the organic dairy market. The downturn was not as bad as 2008-09, which saw quotas and flat sales, but sales did not meet budgeted increases and efforts were, and are still being made to reduce organic dairy production.
A year ago organic feed corn was $14.14; now it’s $10.25 to $12. The recent USDA forecast put non-organic corn at $3.90 per bushel in the coming crop year.
This product is OMRI listed, but only kills by direct contact, so it works best on annual weeds, and will kill anything it comes in contact with. Vinegar burns all of the above ground growth, which is why it is less effective on perennial plants with a strong root system. It might work with multiple applications on buttercup, but it will also kill your grass and clover.
A better approach is probably to change the conditions that promote buttercup growth. It likes wet, compacted and acidic soils, so liming the soil to increase the pH, adding needed nutrients to enhance grass growth and improving drainage will work better in the long run. A soil test will help sort out how best to improve the soils in that pasture.
I suggest contacting the Southern Sustainable Agriculture Working Group. They are an excellent organization of farmers that are committed to sustainable and organic production and are much more familiar with conditions in your region, and have likely dealt with this weed before: http://www.ssawg.org/
200 West Center St.
Fayetteville, AR 72701
P.O. Box 1552
Fayetteville, AR 72702
I read your article on sprouted barley fodder, and I would like to know if I have to use certified organic barley seed to do this?
The scarcity of certified organic meat processors in the Midwest is one of the biggest issues facing the organic industry. The recent loss of the organic processor Premier Meats in southwest Wisconsin has brought this issue to the forefront. There are very few certified meat processors left in Wisconsin and only two of them handle poultry. The lack of certified plants places organic farmers at an economic disadvantage. Either we are unable to label our products as organic, or are forced to raise prices due to the greater distance and time to haul and process our animals.
I encourage you to ask meat processors near you to consider adding organic certification to their services. The rapid growth in consumer demand represents real opportunity to expand clientele and services. Processors can learn more from MOSES or the Organic Processing Institute (www.organicprocessinginstitute.org).
I’ve compiled a list of certified organic meat processing plants in Wisconsin, Minnesota and Iowa. Many of these are included in our Organic Resource Directory. Farmers in other states can find a certified organic processor by searching the USDA website (apps.ams.usda.gov/nop/, select “handling” and your state for a list).
Black Earth Meat Market
1345 Mills St., Black Earth, WI 53515
608-767-3940 | www.blackearthmeats.com
Weber Processing Plant (beef, hogs)
725 N. Jackson St., Cuba City, WI 53807
608-744-2159 | www.webermeats.com
Sonday Produce, LLC (poultry)
E870 Highway 54, Waupaca, WI 54981
715-572-1477 | www.sondayproduce.com
Pete’s Meat Service, LLC (beef, pork, sheep)
1665 Main St., Rudolph, WI 54475
Springbrook Meats, LLC (beef)
N3485 810th St., Elk Mound, WI 54739
Twin Cities Pack (poultry)
5607 East County Hwy J, Clinton, WI 53525
608-676-4428 | www.twincitiespack.com
Halal Food Processors
900 66th Ave. SW, Cedar Rapids, Iowa 52404
319-366-8327 | www.halalfoodprocessors.com
Amend Packing Co (beef)
410 S.E. 18th St., Des Moines, Iowa 50317
515-265-1618 | www.amendpackingcompany.com
220 W. 1st St., Earlham, Iowa 50072
515-758-9545 | www.lpb-inc.com
Premium Iowa Pork, LLC (pork)
108 First Ave. S., Hospers, Iowa 51238
712-752-8666 | www.premiumiowapork.com
Northern Pride Inc. (turkeys)
401 S. Conley Ave., Thief River Falls, MN 56701
218-681-1201 | www.northernprideinc.com
Kb Poultry Processing LLC (poultry)
15024 Sandstone Drive, Utica, MN 55979
507-932-9901 | www.kbpoultryprocessing.com
Ledebuhr Meat Processing, Inc. (beef, pork, lamb)
5645 6th St., Winona, MN 55987
507-452-7440 | www.ledebuhrmeats.com
Swanson Meats, Inc. (beef)
2700 26th Ave. S., Minneapolis, MN 55406
612-721-4411 | www.swansonmeats.com
Lorentz Meats (beef, poultry, hogs)
705 Cannon Industrial Blvd., Cannon Falls, MN 55009
507-263-3618 | www.lorentzmeats.com
TFC Poultry (poultry)
103 Melby Ave., Ashby, MN 56309
218-747-2749 | firstname.lastname@example.org
Organic feed prices also have moderated in the Midwest and East (but not in the West, due to the California drought). These factors, combined with strong conventional prices, make this is an ideal time to transition to organic dairy—but, you do need to do some homework first.
Before beginning your transition, you should make sure there is a market for your milk. Start by contacting one or all of the organic milk buyers in your area. (Search the online Organic Resource Directory for “milk” to find a buyer near you.) Most of these companies manage their supply closely and commit to transitioning farmers far in advance of the date they can start shipping organic milk. This commitment is key, as it makes no sense to undergo the expense of certification, or of buying organic feed, until you know when and if you can start selling organic milk.
Most companies like to bring on new producers in the fall or winter rather than the spring and summer when their milk supply is naturally at the highest peak. The milk buyers will deter¬mine if they need your milk (supply), if you are on or near one of their milk truck routes (location), and determine when you can be ready to ship organic milk (timing).
If they need your milk, and the logistics and timing works out, they will put you in their milk plan and, as you approach your one-year herd transition, make a commitment to pick up your milk once your organic certification has been completed. This commitment is very help¬ful if you need to secure bank loans during the transition. The timing also will determine how you manage your transition—specifically, when you begin your one-year herd transition.
To transition a dairy, the land needs to be managed without prohibited inputs for three years and the herd needs to be managed organically for one year. The National Organic Standards allow a dairy to transition the herd along with the land during the third year of transition. This is a critical point, and one that can greatly reduce feed costs. During that third year, you must manage the herd without antibiotics or prohibited herd inputs, and feed them exclusively your own third-year transitional feed, or purchased certified organic feed.
If you have been managing your land without prohibited inputs already, you may only need to complete the one-year herd transition. Contact MOSES or a certification agency to determine your transition timetable. MOSES also can assist with finding an organic milk buyer in your area.
The rain we've had has made my pasture too wet to graze my herd. How can I meet the livestock grazing requirement of 120 days?
In addition, the National Organic Program regulations are very clear that the grazing sea¬son for your organic ruminant animals need not be continuous, just must total a minimum of 120 days when they are grazing. Your organic system plan must provide for acceptable grazing opportunities for the full grazing season, when weather cooperates. If there is a dry spell for two weeks at the end of August, you can feed hay to your cattle. Once the pastures improve in September, the animals should be allowed to graze.
You should have enough pasture acreage to provide a minimum of 30% dry matter intake from grazing for all of your ruminants for the full grazing season during a “normal” year. The minimum 120-day requirement is only for areas where the typical grazing season is that short, or there is a significant weather event that causes you to have a shortened grazing season. The typical grazing season in the Upper Midwest is 160-180 days. Use of intensive or rotational grazing management systems can greatly improve the quantity and quality of pasture for your animals.
The percent of dry matter taken in can be averaged over the whole season to meet the rule. For instance, your cattle may receive 60% dry matter intake from grazing in May, June and July and 10% dry matter intake from grazing in August, September and October (due to drought). You would average 35% with this scenario and that would be acceptable. The National Organic Program also has allowed a special exemption for less than the 30% dry matter intake from grazing when the USDA Secretary declares a region a disaster due to drought. However, there is no provision in the regulation to allow non-organic hay, forage or other feeds to be fed to organic livestock, even when a disaster has been declared.
This product combines soap with enzymes to destroy the exoskeleton of the lice. It is very effective and non-toxic.
As always, you must call your certification agency to get approval on the use of any new product. Never apply any new product without prior approval.
Can I sell organic fruits and vegetables from plants and planting stock I buy at my local garden center?
The land you raise them on must be free of prohibited materials for 36 months prior to your first organic harvest. If you have planted nonorganic annual transplants in the same fields in the past, your certification agency may consider the land to be nonorganic, and require you to wait three years after that planting to have your first organic harvest. This decision may depend on whether the plants were bare root or were transplanted with their nonorganic potting mix. There is some difference between certifiers.Some allow one year to pass and others require three years. The interpretation of this regulation is something you want to discuss with your certification agency if you are requesting organic certification for the first time.
Your transplants cannot be purchased from an “exempt from certification” (under the $5,000 limit) operation. They must be certified organic, grown by you or someone else who has a valid organic certificate. Some natural food stores may be able to provide you with an organic certificate for the plants they sell, but most garden centers do not sell certified organic transplants.
You can grow the transplants yourself, using approved planting media which does not contain any synthetic fertilizers, fungicides, wetting agents or other prohibited materials. These items are not mandated to be listed on the label of commercially available potting media, so you must get information in writing from the manufacturer detailing the ingredients, stating that the media has not been treated with prohibited fungicides, insecticides, etc. There are many organically approved potting mix and input suppliers. For resources, see the MOSES Resource Directory or the OMRI Products List.
Be very careful when purchasing any fertility input or potting mix, since the word “organic” on these items does not always mean the same thing as “approved for organic production.” Long before the USDA organic regulation, the word “organic” on a label meant it contained the element carbon. To find products you can use, you must look for the OMRI seal and the words “approved for organic production.” Always verify with your organic certification agency that whatever you want to use is acceptable before you buy it.
For fruit trees, raspberry bushes, or other perennials, you are mandated to search for organic planting stock. However, if you cannot find the variety, quality or quantity you want as organic, you can use non-organic planting stock. You must document this search.
In a recent National Organic Program guidance it was clarified that an organic harvest from non-organic planting stock can be done immediately after beginning organic management and planting into organic soil. However, you cannot create and sell organic planting stock from parent nonorganic stock until it has been managed organically for 12 months. For example, you can plant non-organic strawberry plants and harvest an organic crop that same year after planting (after failing to find commercially available organic plants) whether you manage the strawberries as an annual or a perennial. If you buy a non-organic tarragon plant, you can sell the tarragon as organic immediately after planting in organic soil, but could not make cuttings and sell those as organic tarragon plants for 12 months.
Items such as potatoes, garlic, and sweet potatoes (in other words, roots, tubers, rhizomes, shoots, leaf or stem cuttings) are subject to the organic search, and can be planted as non-organic if none were found. However, each year there is more and more availability of these items as organic, and your search must truly cover not just your local store, but also the many mail order and internet operations that sell these items.
Yes, you can plant non-organic strawberry plants and sell the fruit as organic with no waiting period, provided you have documented a search and could not find commercially available organic strawberry plants.
The requirement for planting stock is similar to that for commercially available organic seeds. You must use an organic version unless you cannot find it in the variety, quality or quantity that you need. You must document your search for organic strawberry plants or other types of planting stock. If you cannot find them in the type, quality or quantity you need, then you can plant non-organic plants and sell the fruit as organic.
In February 2013, the National Organic Program (NOP) updated guidance on whether or not “planting stock” such as strawberries, raspberries, tree fruits, and herb plants needed to be under organic management for one full year before selling the production from these plants as organic. Many certification agencies had required a year of organic management. With the update, the NOP clarifies that the one year of organic management is only required when a grower is selling the planting stock itself as organic.
You can sell strawberry fruit as organic at any time from a non-organic strawberry plant. However, the runners from that plant must be under full organic management for a year before you can sell them as “organic planting stock.” Also, you can sell rosemary or lavender leaves as organic from non-organic plants recently planted on your organic farm, but you must manage the plant organically for one full year before you can make cuttings and root them to sell as organic plants.
Before you take drastic steps, determine if the damage is at an economic threshold where you need to take control measures. Knowing the life cycle of the pest bothering your vegetables will tell you if the population numbers can rise very quickly, or if they tend to lessen over time. Your understanding of the insects’ needs and dislikes will help you manage them over time. In a war where only numbers are considered, insects tend to win. In a war where knowledge is the main weapon, humans have the upper hand.
The organic regulation has a pest control hierarchy that mandates you start with cultural, biological or mechanical practices to manage pests, weeds and diseases. When those don’t curb the problem, you can use natural products. After that—but only as a last resort—you can use synthetic materials that are on the National Organic Program’s National List of Approved Substances. Use of synthetics should be avoided as much as possible; broad spectrum insecticides kill beneficial pollinators or predatory insects along with problem insects.
Organic agriculture is a system of production, not just a way to grow food by substituting organically approved materials for non-approved ones. Keep track of problems you have had in the past and seek out resistant varieties (cultural control). Grow habitat beneficial to insects that prey on your pests (biological control). And, use exclusion devices like netting or floating row cover (mechanical control) to protect the tender young plants so favored by insects.
Research has shown that insects favor weak and stressed plants; healthy plants are less attractive to pests. Try foliar feeding your plants with a fish emulsion and seaweed blend to boost their immune system, both to help them recover from the insect damage and to discourage further infestation. Consider starting a regimen of foliar feeding when your plants are usually stressed, such as right after transplanting, when they flower and when they set fruit. Improving the health of the plant also helps you achieve higher yields of quality crops.
Another management technique is to plant a trap crop that is highly favored by your problem insects, and then spray an approved pesticide only on that crop. If you need to move to your last resort of approved synthetic materials, check out Peaceful Valley Farm and Garden Supply’s pest solution chart (www.groworganic.com/weed-pest-control/organic-pest-control. html). This cross-referenced chart of problem insects and control materials is very useful.
As you learn more about insect life cycles and how insect pests interact with your environment, you can help your plants become less vulnerable to insect problems.
Aphids are sucking insects that weaken plants by sucking up sugars and other fluids from crops. They are not easy to see, since they are the same color as the plant stem and generally like to feed on stems, buds, and underneath leaves.
Step one for control is to monitor your crops on a regular basis. Infested plants are often stunted and can be a lighter green or yellow. Look closely at the stems under the leaves for aphids. A magnifying glass or loop can help. A good approach that saves time is to flag “sentinel” plants. Mark plants in a grid pattern and only monitor those specific plants on at least a weekly basis. If you find significant numbers of aphids on these plants, you know it is time for control options. Yellow sticky cards are another good monitoring device. Adult female aphids have wings and are strongly attracted to the color yellow, which mimics the color of sickly plants. The cards are coated in sticky glue, which traps them. Check cards at least weekly for signs of adult aphids. Sticky cards need to be replaced frequently to work well. Fortunately they are cheap and available through any greenhouse supply company.
If you have any infested plants in a greenhouse or high tunnel, you should begin control options since their numbers can explode quickly.
Here are your options as an organic farmer:
There are a number of predators and parasites available for purchase and release. Ladybug larvae are the most familiar, but there are parasitic wasps, lacewings and others available now as well. Biological controls work best to keep aphid levels down, but may not give good control if you already have a problem. They simply cannot reproduce as quickly as aphids (which can actually reproduce without males- females give birth to clone daughters). Beneficial insects work best as preventative controls. A number of companies sell beneficial insects, including:
Soapy water will kill aphids. The soap strips away their waxy cuticle and they die of dehydration. In order for this to work, they must be directly sprayed with the soapy water. Use a sprayer and mix one tablespoon of liquid soap per gallon of water. (Dr. Bronner’s is pure soap. Be careful not to use soaps with perfumes, dyes or other synthetic additives.) There are also many ready-to-use brands that are OMRI listed including the common Safer Insecticidal Soap.
Allowed Chemical Sprays
Remember that all insecticides approved for organic use are “restricted use” products. You can use them only when your other control options have failed, and you must notify your certifier if you intend to use a new product and the reason you must use it. Pyrethrum/pyrethrin-based sprays will work on aphids, but have a very short residual effect and must come in contact with the aphids. The product Pyganic works well, since it is pyrethrin mixed with oil, which coats and kills aphids and many other insects. Your certifier should be able to provide a list of approved pyrethrum/pyrethrin sprays or check the OMRI website for a list: www.omri.org.
Aphids also love plants that are over-fertilized with nitrogen. If they are a constant problem despite other control efforts, you might be adding too much nitrogen to your potting mix or through fertilizer applications. A tissue test to determine nitrogen levels may be in order if you are having ongoing issues with aphids and other sucking pests.
As always, crop rotation and good sanitation practices can help control aphids in the long run.
Soils & Systems:
Feed and bedding: Arsenic is the only prohibited feed input that could have been fed to non-organic animals, which would prohibit use of manure on organic land. Arsenic has at times been added to conventional broiler chicken feed. It is an element, and will remain in your soil since it does not break down. You must document that this is not in the feed if you are using broiler manure. Other than this, animals could have been fed genetically engineered (GE) feed, or given antibiotics or hormones, and the manure is still allowed on organic land.
However, if the manure includes bedding, it cannot contain prohibited synthetics, like treated wood shavings or glues/paints/heavy metal-based inks. On the other hand, GE corn stalks, or any conventionally raised crop is allowed as bedding in manure that can then be spread on organic land.
Piles and Lagoons: You must obtain a document from the manure supplier that a manure pile or manure lagoon did not have prohibited synthetic items used in or on the manure. For example, no non-approved fly sprays or herbicides may be used on manure piles, or non-approved synthetics put in manure lagoons to control odor. A natural lactobacillus bacterium is allowed as a manure lagoon additive, as long as it does not contain non-approved synthetics. Manure that has been piled outside or in a barn for 10 years with no turning and/or no documentation that it reached the high temperatures required for compost (see below) is still considered raw manure, and can only be used according to the manure restrictions on human consumed crops.
Human-consumed crops: If you are growing crops for human consumption, and the manure is not composted or processed, the manure must be incorporated either 120 days before harvest of the crops where the crop has contact with soil (either growing in or on the ground, or where rain might splash soil on the crop, such as beets, tomatoes, peppers), or wait 90 days before harvest where the crop does not have contact with soil (i.e. corn or soybean seed).
Compost and processed manure: Manure that has been composted (documented temperature of over 131 degrees for 15 days and turned 5 times) or processed (150-165 degrees for one hour and tested to have less than 1000 most probable number (MPN) of fecal coliform and 3 MPN salmonella per 4 gram sample) can be used up until day of harvest with no restriction. If you are composting only vegetative matter, without any animal by-products, then there is no requirement to track the compost reaching a specific temperature. Non-animal product compost can be spread this on your organic crops at any time.
Using manure: Be aware that raw manure that has not reached the high temperatures of composting or processing will contain viable weed seeds. You will be adding more, and possibly different, weed seeds to your fields. It is a good idea to obtain an analysis of the manure you are using so you can better manage for the nutrients it provides.
Compost that might contain manure must meet the composition, temperature and turning specifications in the National Organic Standards:
(i) Established an initial C:N ratio of between 25:1 and 40:1; and
(ii) Maintained a temperature of between 131 °F and 170 °F for 3 days using an in-vessel or static aerated pile system; or
(iii) Maintained a temperature of between 131 °F and 170 °F for 15 days using a windrow composting system, during which period, the materials must be turned a minimum of 5 times.
The county/city must provide the documentation to show these standards were met before you can use a material as compost. If they cannot prove they have met these standards, it may be possible to still use it, but it will not be considered compost, it will be considered raw manure, and will have different handling requirements:
1) Raw animal manure, which must be composted unless it is:
(i) Applied to land used for a crop not intended for human consumption;
(ii) Incorporated into the soil not less than 120 days prior to the harvest of a product whose edible portion has direct contact with the soil surface or soil particles; or
(iii) Incorporated into the soil not less than 90 days prior to the harvest of a product whose edible portion does not have direct contact with the soil surface or soil particles;
Composted and un-composted plant materials without manure have no application restrictions, but the composting center must verify that the compost contains only 100% plant materials. If there is a possibility that it contains pet waste (animal manure) then it must be handled as raw manure.
Whether or not it contains animal manure, you still must make sure compost contains no prohibited materials:
•Recycled building materials/lumber (due to paints, varnishes and glues)
•Plastics and other un-compostable synthetics
Check with the composting facility to see if they have the necessary documentation. If other organic farmers have been using their product, it is quite likely they have this paperwork on hand. Also check with your certification agency, which can do a product review if it has not already reviewed this compost for other farmers. Ultimately, your certifier makes the final call on whether a product is allowed or not. All new inputs should always be verified and added to your crop input list before use.